The good the bad the ugly quotes -

The good the bad the ugly quotes

The good the bad the ugly quotes Video

Tuco Benedicto Pacifico Juan Maria Ramirez (The Good, The Bad And The Ugly)

The good the bad the ugly quotes - sorry, that

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Which brings us to the district court case mentioned in my prior blog, Gentges.

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Gentes for a number of years held two accounts at UBS in Switzerland: account ending in and account ending in He failed to file FBARs for Gentges to reduce the assessments to judgment. It filed a motion for summary judgment, which the court granted in part and denied in part. The facts are straight forward: when opening both UBS accounts Mr. Gentges signed documents stating that a he was electing to have the accounts numbered, b he wanted all mail from UBS held, c did not want any investments in U.

He claimed he signed the documents where he was directed and did not read them over carefully. He picked up his mail from the bank during his frequent visits to Switzerland.

He and his wife set up a trust to which they transferred their home in the U. Gentges used the same CPA to prepare his returns for many years. He never disclosed his Swiss accounts to the CPA and never asked him about reporting foreign accounts. He would send his information to the CPA every year to prepare his tax returns without any information on the Swiss accounts.

the good the bad the ugly quotes

Gentges signed his returns under penalties of perjury. When Migros Bank informed him it no longer would do business with U. The issues before the court were. Gentges concededthe court held that for purposes of the civil FBAR penalty willful includes both knowing and reckless violations of the statute. The court stated that Mr. Following the weight of authority for appellate and district court cases around the country, the Court concludes that Defendant recklessly disregarded the FBAR filing obligation by failing to carefully review his income tax return and erroneously representing that he had no financial interest in foreign accounts.

the good the bad the ugly quotes

Clemons MD Fla.]

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